Fair, Accessible, and Timely Handling of Customer Complaints
P R I V A T E & C O N F I D E N T I A L
Issued by: NoLimit Payments Ltd.
Effective Date: 12 June 2026
Governing Law: Province of Ontario, Canada
Review cycle: annual, or upon material regulatory or operational change
This Complaint Handling Policy (this "Policy") sets out how NoLimit Payments Ltd. ("NoLimit", "we", "us", or "our"), a corporation incorporated under the laws of Canada (corporation number 1444218-1) with its principal office at 325 Front St W, Unit 200, Toronto, Ontario M5V 2Y1, Canada, receives, handles, investigates, resolves, and records complaints from customers and end users of its Services. NoLimit is a registered Payment Service Provider supervised by the Bank of Canada under the Retail Payment Activities Act ("RPAA"), a Money Services Business registered with FINTRAC (#M23055482), and a Money Services Business registered with the U.S. FinCEN (#31000309349602).
This Policy is the internal governance document for complaint handling. The customer-facing summary published on the Platform, and the complaint-handling reference in our Terms of Service, are derived from and consistent with this Policy.
The following terms apply:
1.1 Purpose. NoLimit is committed to treating its customers fairly and to resolving complaints in a prompt, fair, accessible, and well-documented way. This Policy establishes a consistent framework for handling complaints, supports the fair treatment of customers, and feeds the operational-risk management and continuous-improvement frameworks that NoLimit maintains as a registered Payment Service Provider.
1.2 Scope. This Policy applies to complaints received from customers and end users (each, a "Complainant") about the Services, the Platform, our staff, or our service providers, however the complaint is received. It applies across the markets in which NoLimit offers the Services. The Services are not offered to residents of the Province of Quebec; where we nonetheless receive a complaint from a person in Quebec, we handle it fairly under this Policy.
1.3 Relationship to Other Processes. This Policy works alongside, and does not replace, the following, which govern where they apply:
(a) Error resolution and unauthorised transactions — handled under the Terms of Service and applicable law (including, for U.S. prepaid cardholders, the error-resolution and timing rules under the Electronic Fund Transfer Act and Regulation E, and the card-network rules) rather than under this Policy, although a Complainant need not classify a matter correctly and we will route it appropriately;
(b) Payment-card disputes and chargebacks — handled under the applicable card-network rules and the cardholder agreement; and
(c) Privacy complaints — handled under our Privacy Policy by our Privacy Officer, with external recourse to the Office of the Privacy Commissioner of Canada and, in Quebec, the Commission d'accès à l'information.
2.1 Definitions. In this Policy:
(a) "Complaint" means an expression of dissatisfaction about the Services, the Platform, our conduct, or our handling of a matter, whether justified or not, where a response or resolution is expressly or implicitly expected. A general question, a feature request, or routine feedback is not, by itself, a Complaint, but is treated as one if the person indicates dissatisfaction and expects a response.
(b) "Business Day" means a day other than a Saturday, Sunday, or statutory holiday in the Province of Ontario.
(c) "Complaints Officer" means the individual designated under Section 6 as accountable for this Policy and for the oversight of complaint handling.
(d) "Final Response" means our written communication to the Complainant that sets out the outcome of the Complaint under Section 5.4.
3.1 Fair Treatment. We handle every Complaint fairly, impartially, and in good faith, on its merits, and free of charge to the Complainant.
3.2 Accessibility. Complaints may be made through more than one channel (Section 4). We provide reasonable accommodation to Complainants who need assistance to make or pursue a Complaint, and we communicate in plain language.
3.3 Timeliness. We acknowledge and resolve Complaints within the timeframes in Section 5, and we keep Complainants informed of progress.
3.4 Independence and Escalation. A Complaint that is not resolved at first contact is escalated to a person with the authority and the independence to assess it objectively, and ultimately to the Complaints Officer.
3.5 No Reprisal. No Complainant will be penalised, and no customer relationship will be adversely treated, for making a Complaint in good faith.
3.6 Confidentiality. Complaints are handled confidentially and in accordance with our Privacy Policy and applicable law; information is shared only with those who need it to investigate and resolve the Complaint or as required or permitted by law.
3.7 Regulatory Context. The Bank of Canada supervises NoLimit's compliance with the RPAA, focusing on operational risk, incident response, and the safeguarding of end-user funds. The Bank of Canada does not resolve individual disputes between a Payment Service Provider and its end users. This Policy is part of how NoLimit manages operational risk and treats customers fairly; it does not limit any right a Complainant has under applicable law.
4.1 Channels. A Complainant may submit a Complaint:
(a) by email to support@nolimit.money (or complaints@nolimit.money);
(b) through the in-app or in-platform support function; or
(c) by mail to NoLimit Payments Ltd., Attn: Complaints Officer, 325 Front St W, Unit 200, Toronto, Ontario M5V 2Y1, Canada.
4.2 Helpful Information. To help us resolve a Complaint efficiently, a Complainant is invited (but not required) to provide their name and account details, a description of the issue, the relevant dates and amounts, what resolution they are seeking, and how they prefer to be contacted. We do not refuse to handle a Complaint because it omits this information.
4.3 Representatives. A Complainant may use an authorised representative. We may verify the representative's authority and the Complainant's identity before disclosing account information or acting on the Complaint.
5.1 Front-Line Resolution (Tier 1). We aim to resolve Complaints at first contact wherever possible. Front-line staff are empowered to resolve straightforward Complaints promptly.
5.2 Acknowledgement. We acknowledge each Complaint that is not resolved at first contact, normally within five (5) Business Days of receipt, and tell the Complainant who is handling it and how to reach us.
5.3 Investigation (Tier 2). A Complaint that is not resolved at Tier 1 is escalated for investigation by a person independent of the subject matter of the Complaint, and, where appropriate, to the Complaints Officer. We investigate fairly and gather the relevant facts, records, and context.
5.4 Final Response. We provide a written Final Response that, to the extent appropriate, summarises the Complaint, explains the outcome and the reasons for it, describes any redress or corrective action, and tells the Complainant about the external escalation options in Section 8. We aim to provide the Final Response within thirty (30) calendar days of receiving the Complaint.
5.5 Where More Time Is Needed. If a Complaint is complex and cannot be resolved within thirty (30) days, we tell the Complainant before that period ends, explain why, and give an expected timeframe, and we aim to provide the Final Response as soon as possible and in any event within sixty (60) days, except where a matter is subject to investigation, legal proceedings, or a regulatory or law-enforcement constraint.
The standard timeframes are summarised below. These are NoLimit service standards; where a specific law, card-network rule, or regulatory requirement sets a shorter or different timeframe for a particular matter (for example, Regulation E error resolution for U.S. prepaid cardholders), that requirement governs that matter.
| Stage | NoLimit Service Standard |
| Acknowledgement | Within 5 Business Days of receipt |
| Status update | If not resolved within 30 days, an update with reasons and an expected timeframe |
| Final Response | Within 30 calendar days; for complex Complaints, as soon as possible and in any event within 60 days |
5.6 Resolution and Redress. Where a Complaint is upheld in whole or in part, we take proportionate corrective action, which may include correcting an error, reversing or refunding a charge, releasing a hold (subject to compliance and legal constraints), apologising, and addressing the root cause to prevent recurrence.
6.1 Complaints Officer. NoLimit designates a Complaints Officer, within the Office of the General Counsel, who is accountable for this Policy, for oversight of complaint handling, for handling escalated Complaints, and for periodic reporting under Section 7.
6.2 Front-Line and Support Staff. Staff who interact with customers are responsible for identifying Complaints, attempting first-contact resolution, recording Complaints in the complaint register, and escalating in accordance with this Policy.
6.3 Senior Management. Senior management is responsible for supporting a fair-treatment culture, allocating adequate resources, and reviewing complaint trends and the effectiveness of this Policy.
6.4 Training. Relevant staff receive training on this Policy, on identifying and handling Complaints, and on the fair treatment of customers, on joining and periodically thereafter.
7.1 Complaint Register. We record each Complaint in a central register, including the date received, the Complainant and channel, the nature of the Complaint, the investigation and outcome, any redress, and the dates of key communications.
7.2 Retention. We retain complaint records for at least the period required by applicable law and our records-retention schedule, and in any event for not less than five (5) years, consistent with our AML record-keeping practices.
7.3 Root-Cause Analysis and Trends. We analyse Complaints for root causes and trends and feed the results into our operational-risk management and product-improvement processes, so that recurring issues are identified and addressed.
7.4 Internal Reporting. The Complaints Officer reports periodically to senior management on complaint volumes, themes, resolution times, and corrective actions, and escalates significant or systemic issues promptly.
7.5 Regulatory Cooperation. We cooperate with the Bank of Canada and other regulators and provide complaint records and information as required or requested under applicable law, including in connection with the Bank of Canada's supervision of our operational-risk and incident-response frameworks.
If a Complainant is dissatisfied with the outcome of our Final Response, or if the Complaint has not been resolved within the applicable internal timelines set out in Section 5, the Complainant may, where legally available, seek external review through the relevant independent bodies identified below.
For clarity, external bodies are independent authorities or dispute-resolution mechanisms. They do not act as extensions of the internal complaint process and may apply their own admissibility criteria, including thresholds for relevance, jurisdiction, and substantiation.
Where appropriate, we will identify relevant escalation channels in our Final Response.
The available external escalation channels may include:
| Subject Matter | External Body / Mechanism |
| Regulatory matters relating to NoLimit’s activities as a regulated payment service provider | Relevant supervisory authority, including the Bank of Canada (noting that it does not adjudicate individual disputes or provide case-specific remedies) and applicable provincial or federal consumer protection authorities |
| Card-related transactions | Applicable card scheme dispute resolution mechanisms and, where relevant, the U.S. Consumer Financial Protection Bureau (CFPB) for U.S.-issued instruments |
| Privacy and personal data protection matters | NoLimit’s appointed Privacy Officer and, where applicable, the Office of the Privacy Commissioner of Canada and/or the Commission d’accès à l’information du Québec |
Nothing in this Policy restricts, limits, or excludes any statutory or contractual rights available to a Complainant under applicable law.
This includes, without limitation, the right to:
This Policy is intended to facilitate the fair, proportionate, and efficient resolution of genuine complaints.
Accordingly:
The Entity is committed to maintaining a safe working environment for its employees and representatives.
Accordingly:
9.1 Owner and Review. This Policy is owned by the Office of the General Counsel and is reviewed at least annually and upon any material change in the Services, the law, or our operations.
9.2 Exceptions. Any exception to this Policy requires the prior written approval of the General Counsel and is documented.
9.3 Related Documents. This Policy should be read with the Terms of Service, the Privacy Policy, the customer-facing complaint summary published on the Platform, and NoLimit's operational-risk and AML frameworks.
